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Home My WebLink About12-6479~' ~ .~., iv ~-• ,. Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1 FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF Vs. MARY E. KANISH-THORNTON CIVIL ACTION -LAW ERIC R. THORNTON a/k/a ERIC THORNTON DEFENDANTS MORTGAGE FORECLOSt1RE NOTICE TO DEFEND AND CLAIM RIGHTS THIS LAW OFFICE IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEB'C. YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth. in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claims or relief requested by the Plaintiff. You may lose money ar property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAW~C'ER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY ~'M~~ Ib~~ S ~~d a~ ~~ ag a ~ OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717)249-3166 OR (800)990-9108 NOTICIA Le han demandado a usted en la corte. Si usted guiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) Bias de plazo al partir de la fecha de la demanday la notification. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objectiones a las demandas en contra suya. Se ha avisado que si usted no se defiende, la corte tomara medidas y puede entrar una Orden contra usted sin previo aviso o notification y por cualquier queja o alivio que es pedido en la peticion de demanda. LISTED PUEDE PERDER DINERO O O"TROS DERECHOS IMPORTANTES PARA LISTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI U~TED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SU PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717)249-3166 OR (800)990-9108 IF THIS IS THE FIRST NOTICE; THAT YOU HAVE RECEIVED FROM. "PHIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. SECTION 1692 et seq.(1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. UNLESS YOU DISPUTE "THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF WITHIN THIRTY (30) DAYS OF THE RECEIPT OF TINS NOTICE, COUNSEL FOR PLAINTIFF WILL ASSUME THE DEBT TO BE VALID. IF DEFENDANT(S) NOTIFY COUNSEL FOR PLAINTIFF IN WRITING WI"THIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND MAIL TO DEFENDANT(S) WRITTEN VERIFICATION OF THE DEBT. LIKEWISE, IF DEFENDANT(S) PROVIDE COiJNSEL FOR PLAINTIFF W [TH A WRITTEN REQUEST WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR. PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. "THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF "THE "THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEB"T. EVEN THOUGH THE LAW PROVIDES THAT YO1JR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THE THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF "THIS COMPLAINT, THE LAW REQUESTS US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSiJLT AN .ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF Y"OU HAVE FILED BANKRUPTCY AND/OR RECEIVED A DISCHARGE. "PHIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. Karl M. Ledebohm, Esq. P.O. Box. 173 New Cumberland, PA 17070-0173 (717) 938-6929 MEMBERS 1 s ~ FEDERAL IN THE COURT OF COMMON PLEAS CREDIT UNION CUMBERLAND COUNTY., PENNSYLVANIA PLAINTIFF ~ Vs. : NO.: ~ ~` - ~D ~ ~ `1 ~--•I U ~ I MAKY E. KANISH-THORNTON ERIC' R. THORNTON a/k/a ERIC THORNTON DEFENDANT(S) :CIVIL ACTION-LAW-MORTGAGE :FORECLOSURE COMPLAINT AND NOW, comes Members 1St Federal Credit Union, the Plaintiff in the above captioned matter, by and through its attorney Karl M. Ledebohm, Esquire, and makes the following complaint: 1. Plaintiff, Members 15` Federal Credit Union ("Members 1'`"), is a National Federal Credit Union having a principal address of 5000 Louise Drive, Mechanicsburg, PA 17055. 2. Defendant, Marv E. R:anish-Thornton and Eric R. Thornton a/k%a Lric. Thornton (hereinafter "Defendants"), are adult individuals having a last known address of 20-B West Glenwood Drive, Camp Hill, PA 1701 1. ~. On or about June 28, :?010, Defendants borrowed from and agreed to repay to Members ls`TWENTY-NINE THOUSAND FIVE HUNDRED AND 00/100 ($29,500.00) dollars (the "Loan"). The Loan is evidenced by a Closed-End Note, Disclosure, Loan and Security Agreement executed and delivered to Members 1 s` by Defendants on June 28, 2010 (the "Note"). A copy of the Note is attached hereto as Exhibit "A" and made part hereof. ~. As security for the Loan, Defendants executed and delivered to Members l sr a mortgage ("Mortgage") on all that certain real estate and improvements erected thereon situate in the East Pennsboro Township, Cumberland County, Pennsylvania, known and numbered as 20-B West Glenwood Drive, Camp Hill, PA 17011 (the "Property"). A description of the Property is attached hereto as Exhibit "B" and. made part hereof. 5. On or about July 29, 2010, the Mortgage was recorded in the Cumberland County Recorder of Deeds Office to Instrument No.: 201020510. A true and correct copy of the Mortgage is attached hereto as Exhibit "C" and made part hereof. 2 6. "hhe Mortgage has never been assigned by Members 1st and is still held by it as a valid and subsisting obligation of Defendant(s). 7. Defendants are in default of the Mortgage and the Note for failure to deliver to Members 1st the monthly payments of principal and interest due thereon on or before the 24t~' of each month in the amount of $361.14 for June through September, 2012, as more particularly described, in part, in the Act 91 Notice attached hereto as Exb.ibit "D" and made part hereof. 8. Members 1st gave written notice of its intent to foreclose Pursuant to the Act of January 30, 1974, F'.L. 13, No. 6, 41 P.S. section 101, et. se ., and in particular section 403 thereof, and of Defendants' rights in accordance with the Homeowners' Emergency Mortgage Assistance Act, Act of December 23, 1983, P.L. 385, No 91, 35 P.S. Section 1680.401(c), et. sec., by letter dated August 29, 2012, addressed to Defendants at the Defendants' last known address set forth in paragraph 2, being the Property, via certified mail., return receipt requested. A copy of the said notice is attached hereto as Exlxibit "D" and made part hereof. 9. Copies of the USPS Track & Confirm statements evidencing the mailing of said Notices are attached hereto collectively as Exhibit "E" and made part. hereof. 10. Simultaneously, Members 1st forwarded to Defendants the same Notices and addressed to Defendants at the same addresses as set forth in paragraph 8 by United States mail, first class, postage prepaid, bearing the return address of Members 1st. The Notices forwarded in said manner have not been returned to 12 13 14 the offices of Members 1St as undeliverable or otherwise. Defendants are indebted to Members 1st in connection with the Mortgage in the amount of TWENTY-SEVEN THOUSAND NINE HUNDRED FIFTY- FIVE AND 56/100 ($27,955.56) dollars itemized as follows: a. Outstanding principal $26,400.?2. b. Interest to October 15, 2012 336.78 c. Late fees 18.06 d. Attorney's fees 1,200.0(} e. Total due to Members 1st $27,9:?5.56 Defendant also agreed under the terms and conditions of the Mortgage that in the event of default there under Defendant would pay, in addition to the amounts set forth in paragraph 11 above, costs incurred by Members 1 s` as a result of the institution and prosecution of these legal proceedings. The obligation evidenced by the Note and the Mortgage continues to accrue interest at the rate of S5.9601 per day, through the date of payment and. continues to accrue attorney's fees and costs. Members 1st is not seeking a judgment of personal liability (or an in personam judgment) against Defendant(s); however, Members lst reserves the right to bring a separate action to establish that right, if such right exists, If one or more of Defendant(s) have received a discharge of personal liability in ~~ bankruptcy proceeding, this action in Mortgage Foreclosure is not an attempt to reestablish such personal liability discharged in bankruptcy, but only to 4 foreclose the mortgage and sell the Property in accordance with Pennsylvania law. 1.5. As set forth above, Members 1St has made demand upon Defendants to pay to Members 1st the amounts due under the Mortgage and the Note. However, as of the date hereof, Defendants continues to refuse and fail to make payment of such amounts to Members 1st WHEREFORE, Plaintiff, Members 1St Federal Credit Union, demands judgment, In Rem, against Defendants, Mary E. Kanish-Thornton and Eric R. Thornton a/k/a Eric Thornton, in the amount of TWENTY-SEVEN THOUSAND NINE HUNDRED FIFTY-FIVE AND 56/100 ($27,955.56) dollars plus interest at the rate of $5.9601. per day, through the date of judgmer.~t and at the legal rate thereafter until the date of payment, additional attorney's fees and costs of suit as well as other costs and charges collectable under the Mortgage and for foreclosure and sale of the mortgaged property. ,. Re~spectfull~ubmitted, ~~~ : -~ .r, .~ ~ ~ ~' _ -__ /.,. i ~v Z, l~., .i a~ _._. Date: ~ f __ ____ Karl M. Ledebohm, F s a Supreme Court ID # :5901'? P.O. Box 173 New Cumberland, PA l 7070-0173 (717)938-6929 Attorney for Plaintiff 5 5000 Louise Drive, P O. sox 40 Mlscheniwburp, PA 57055 1'~ lg` MEMQERS I° e+,o.. PRINDwnL AMDUN r LDAN NIJM¢ER ~DpgpRedwER'8 NAME ~29 50000 - pATE yWJ(~,~ M/t7yrirty~7Ar~ C, FIxED VARV.atE ANNUALPERCENTAGE FINANCE CHARGE: Ar„OUnlFinencedTheamountof Total orPeymantsTneamount RATE: The vest of your cremt as a The dollar amount Iha txedd will uedit provided to you or on your you will have paitl afltx you have yearly rate ' cost you. behall. made ail payments as schedukd. 8Y4 Wo s S 13,875.03 • j 29,500.00 • j 43,375.03 Vuie Ws Rea: If your loan has ^ wdabse role as indicstad above the AMUeI Peroenuge Rsa may increase Itunnp Me term of this lranncLOn rt IM (mdsxJ cnsngu. Ths crodn union will adtl a margin of to the index vsWa. The tale wiY change monMly on the firs) day of Ina monM. Ths tau wn1 never W hpnar than the mrxlmum role alvaed by law, end it will never W Ins Than . My inNrsst me incnssea was rosWt M more payments of the urtr emoum. For Example, H your loan was rot SS o0D al IS% Im+s months and ttK Mnual Percanaps Rate increassa by 2St soar one year, th^ a nn or your loan would Increase by two months `_-- 'Peferrod Raa: II checked, Me WYOwing applies to your loan; I~ Aulomatle Payment Olscounted RaG: Bawusa you have apneed to make your euqured monthly payrcrnts InrouOh en aulomafic deduaon hen your CneckinySaaings hove in the ANNUAL PERCENTAGE RATE boc is J d NT RATE di sc OSe s AGE ccola+l ywr ANNUAL PERCENTAGE RATE hu bean dlscounu by 20K. Tne ANNUAL PERCE ntenl arran ement or fur W msnain suffitlent lunds ti your account to nede s In wt i 2 % Y g y a p naaase oY . you oars a Iha Amomaue Payment OuW unled RMS Thia nta well cover Me submatic payments. In such ^ wee, tM eHeU Of IM Increase veil t>Q to utand Iha arm of Taut Ipen. For exartpb, d your AtrtomaUc Payment Oiscounled Rata is 1 DX on • SS,D00.00 Iban for 60 monlns and you cease IM automatic psymanl smngemenl, y0la rata will Incroasa tb 10.2054, resullinp in 1 atltlillaMl payment Vadxble Raa Probmtl Loans. II your loan Is a vsnaok rate loan and you quetiry for a prdenatl nta, your prclerrsd dtscpunt Is taken st Ina thus you take out your loan. This nilial prounstl ANNUAL PERCENTAGE RATE veil Men vary eceadinp to Ulanpas In the Index (as disclosed above). For example, N a wntrWe rate ban's initial ANNUAL PERCENTAGE RATE fe 12% d the aNw you Saks Me loan, your inMtl preferred ANNUAL PERCENTAGE RATE will bs NlAY., Your initial preferted ANNUA'. PERCENTAGE RATE wig Msn vary acwNing W the Index, ss disclosed in Ina -vsnads Rsti' proNsbn above. Fixed Rate Preferred Loms. I} your loan is a Azad rate Wan and you quaYfy for s prelamd rata, your ANNUAL PERCENTAGE RATE will be Me prekrted ANNUAL PERCENTAGE RATE disUOSed above Wr as loop ss your preferred sates romaim m affad. Number of Psymonu Amoum o! Payments Payment Frequency Wlrn PsymmU An Dw property InaUranea: You may oblainprOperty insurance from anyone you want that +e act~pleble to yo~~ Paympy 119 1361 46 Montht)~ - aepiminp 07f2a12010 s sa r th¢ credo union. 11 ou get the insurance Iron the uedit union you will pay r v ..m a 5361.29 Final Due - On 08124f2020 S N!A s 6acudty: Gwaaral uwtlnp other loans SWth the croon union the geode orproperry vAl also sscuro this loan. You an plvlrtq s setludry Interest in (- Wlnp purchasatl. Other fDescdba): ~ your ohms andlor tlepmn in the uedd union, and: t ^ Lau Charge: II s payment is Iota by 10 days or more you writ Requlrod DepoNt l3auncr. The Annual Parramatya Rsa ones filing Fear. tJonFiUrg Inaunnca: bs Merged a late tee of 5X of your scheduled payment. not lake into scr~unl your required deposit Dsbnu, d soy j N!A j N1A r~ayn,enT:-A Yov nq o • Y, Yw nor eve o pry a aen.~y: T- es Yaur corNecl eeumerna 1 anY ~ b orrro eooN nonpayment ee u any re0u•ea repayrnent m rJl blaf '/' mNrN •ahrryw IM eclletlWtl tleM antl pnpeymeM reWM1 mtl MMlluta. rlem a.r (ruts yr AMQUNT F(NANCED _ 1 -- 29,500.00 Amount Pald to others on your behall (Describe) _, ^_ __ SY.sso.rY TDpISCAVERFW 1 To AMOUNT GIVEN TO YOU OIREGTLY S 2,992-82 'i S To 1 i l o S To S 70 ------ S To 1 To AMOUNT PAIp ON YOUR ACCOUNT $ 19,576.61 1 To S To S To S To S To S T'o ^-' 1 To S To PREPAID FINANCE CHARGE S 0.00 $ To $aoo TO Pee, $tl.ro To Aa.tl sosAiona Sd.otl To Aa.o sowona . _..... ,...- -.. .. - - - ~ .. SECURITY1NfORMATION~ ~- MAKE MODEL YEAR I, D. NUMBER TYPE VALUE OTHER (Described: 20a W GLENWOOD DR. CAMP HILL, PA 17011 You Pladp¢ Shares I AMOUNT ~ AGCOVNi NUMBER I AMOUNT I ACCOUNT NUMBER arsdlor Depomts pf 1 1 Vou epras Mat Me Nrms and condtions in the dudosun saternent and the loan and secudy aprssmsna lotlsad on papa 2 or this Iipcrlmsnl shall appy to Mis tan. It Maro b more Man one bonaer, vre slues Mat all Ihs tlondtllons of Me loan and wwrrty apnrnMS goveminp this loan shay apply to both jofnty sod asvenly You arJtnoMsltgs Mel you eve recaivW • copy of Ma Wan and eeuprry agrosmanu and disdoturc sletsmenl. CO•sgnen I! you aro agninp as oo-Apnar, you adknowletlpa receipt of fhe noacs W caalgner eonLiasd On pace 2. / NOTICE TO CO-SIGNER You ere being asked to uerantee this debt Thfnk carefully Galore you do. M the borrower doesn't pay the debt, you will have to. 8e sure you can aHcrd to pay A you Rave lo, and That yw want to accept ih is responsiblhly. You may have M pay up to the lull emaunl of the tlsW if the borrower does not pay. You may also have to pay late fees Or coOaUion costs, which inueese This amount. Ttw uetlhor Can collect this tlebt Irom you without first Iryinp to colku from the borrower. Iha creditor can use the same collection methods a~ainsl you ;oat can be used against the borrower, such as suing you, parmshing your wages, etc. II Ihis debt is ever In default, that tan may become a part o. your trade recoro. This notice Is rot Ina uxSLact Ihal makes you haDle for lge debt. Exhibit "A" CLOSED-END NOTE, DISCLOSURE, LOON AN^ SEGURiTV A nR MFNT BOfiROVvER'e NAM¢ AND AbDI1Eae MARY E KANISH-THORNTON 20B W GLENWOQD DRIVE CAMP HILL,,PA 1(011 __~_____--„_ At;,~0yT1T.NUMBER WNflr; aver w,,,w ••,•~ frr , n•MIY Inlrwl Ipar aw e, e„nNr p Nppl .•!e W nr ee,•r,M Oa,W rY ,Noe Mrs, TM pop evert. unM,r rw , aewupr. N m etllesr•• a P,1 a'w stet WI Yne.rnrr, a.r r N.1 wwF„ • „vent( ti„rM In IM a,l41pr1 p r1elYMe Inn, spplly a(,erwr,~.. ••COJgNm~ upn eepull,Iti rN,l vnl.n w~q ,,.1, ln„w„p, MY^,nl Y«n wr eprNp•1,rn' u•e ex rr.n d.n ,n Mr ler.liw. e r•r rrr„~,rbmrN,e lrp ,p nwpplr,wp d,„M1I4•er l.r. HORROVVFR'6 NAME LQW NUMBER ACCOUNT NVMBER GATE OF LOAN MARY E KANISH-THORNTON 411171 06128/2010 ItL~MEO AEgA ORROWEq~$)THE WORDS "CREDIT UNION" MEAN: MEMBERS 1ST pE~ERAI CRE01T UNION. THE WORDS 'VOV.' "POUR" AND 'YOURS" MEAN THOSE LOAN AGREEM EN7 PaymantslFlnance Charges. Fot value received, you prixnisa to pay, at the Credit Union's office, all amounts due. All payments shall be made pursuant b the disdowro statement on page 1 of this document Yau understand Nat Iha finance dterge end total t#paymeme shown rm page t of this document ere based on the asstmpUm Ihet aft inslellmenl pa ments wgl be made on the scheduled due dales, and , k you have quehfied Tor pretsrtsd rate that you conbnue to salisH the cond'Alana of that preferred rats. If you fai) to pay any installment by l e time I7 is due, you wRl1 pay additional nteres on the overdue amount Alloc^tion of Payments and Additional Payments: Payments and credits shag be apphad in We following order any amounts past duo; acuued inlerosl or linens 1YtarDes; any fees tx charges owing, Irttluding arty insurance premiums, outatandutD prmupet. Payments made in eddiuon to repufgrly aehsduled payments shall toe apDtiod in the fame ortler. Preferred Rals: If you pualifYy for a preferred rate as disclosed on page 1 of this document or in a aeparaW preferced rate addendum, you unden[end that you must meat the condiltons diadosed to you in order to qualify for the prefered me and must continue to mast (hose conddana In order o keep your prafarrod rata. If you fag to meal those condhions, your taco wgl lrsuease, InereDyy extendlnD the terms of your loan. You promisa to continue making paymen(s and to meet alt abhgalons under Ihis Agreement even d you no Copan receive the preferred role. Late Charyss: If ou make a Iola pa ment, you agree to pay a late charge d once is discosed on page 1 of Ihis document. Property lnsurancs: g you obtain a ban secured by a motor vehicle or Omer lanplbb pr y, you mud obtain insurance which proteuKa the credit union from tinancfal loss. The amount and cover~pa of the progeny hsurance muss be acceptable to the acrid union. Such s policy must provide at least fire, then combined addmonal covnspes and collnton tnsurertce. h must contain a Lass Payable clause endorsement naming Ina aerial union as lien holder. You may obtain Ihis ineurartr~ (ram an agent o} your choiu ens dlred the agent to send the cradil union a Dopy of the policy. Debtor Reeponeibility: You promise to notify uedil union of any rhartge in your name, address or employmanl. You promlae not to eppy for a loan K you know ttwre is a reasonable probabglty that you wilt be unable to repay yyour obttgatlon according to me terms of tTte uedll extension. You promise fo inform uedil unbn of any new informatbn which relates to your ebdily to repay your oblipalion. You promise not to submd fete or inaccurate in ormaUOn or willluily conceal mlormation regarding yow creditworthiness, credit Blending, or credit capaaty. Oefsult: You shall ba conside fad in default if anY of the follow-.ng occur; 1) II you break any promise made tlrtder this Loan Iigreemenl or under the Security Agreement; or (2) H ou do not use the money the uedd union foanad yyou for the purpose stated in your application; or (3) it the uedif union s7iould, in d la'dh, believe that prospect of yment, performance or reaFzatbn of Ifie collateral, B any, is impaved; or g4) d you d+e; or (5) if you file a gpelation in bankruptayy., insolvency, w receiverehtp or era put Involumarlly Into such proceedings; or (6 d the collateral, d any, given as securityy for this amount is loaf, damaged or desUoyed, or it d is levied a ainst, atladtetl or garnished; or (T) d you do not pay on time grey of your o~er or future debts to the credit union. If you default, Iha uedil unbn may. al the uedt union's option end without prior police, dedsre Ihis loan Mmedlately tllse errd payable, end you must immedtetety pay to the uisd8 union al that time the !o(al unpaid balance, as well as the Finance CitarBe to dale, any late charges and costs of collection permuted untler law, 4tduding reasonable attorneys Tees, that the credit union may incur, up to 20X of the unpaid principal and interest. Costa of collection incLde, but are rr~t Ilmitetl to, rcpaesebaion fees, appraisals, environmental site assessments, psuaity damage insurance covsrape, and sROmey's foes for any aUlon taken by an atlornay In order to collet lhls Ioen or preserve Or protect the uedit union's riohls end remedies. including, without limaaaon, pertrespa6on in bankruptcy cases, masers, and proceedmpps tinclwinp, wihout limRetian, filing proMs of claim, pursuing reaJfsma2'ixt apreemenls. allending maelh s of ued rtora, end pursuinG compleinls, mdions, end objections that reQete in any way to the credit union's collateral or nght ta, pa ,ment), collateral disposdion, non-bankruptcy suits and/or adminlalralrve adlona, and appeals. The principal balance m default shall bear Interest at the contract rate. Statutory Uert; tf you are 'n daleull, federal law Dives the credit union the right to apply the balance of shares and/or dividends in your axount(s al the time of tlelault to cabsry this loan. tAtce you, are in detauh, the cr II union may exercise this right without turttser nonce to you Daley in F-nforcamant: Credit Union may delay anlorcinD any of the uedit union ngMs under this sgreement without lositg Them. tvogular P^ymantc: TM cradil union may eaePt rate paYmauls or parual payments, even though marked "payment m Full,' without bsing any of the crodil union rlDhls ungtler Ihis agreement. eowtsakero: If you are s'gnhD Ihis agreement as a co-maker, you agree to !te squally responsible with the barowar, but the credit union may sue either or Coln d you. The aedtl union does not have to notify you that this agreemem has not been peltl, The credit union may extend Uta lanes of payment and release any secunty wllhoul noUfymg or re leasinD you from reaponslbihry on this agreement. SECURITY AGREEMENT 1, To secure peyln!,nt ol.mis`losn aM rna ass unry nice est includes alt menaces, is to 1Fte sacuro property, proceeds from arty property and all umings nniwd from the oparty givegea sac entry for thl6_Iwn a for any Ina pro er mcisafon riodbea an en aatPilled). Oran norrquRhaee Y. 1 a rnd11 union i prio wtbitlintoniiij I or tnnafar the colkslsnl unlese'rou nave J. You vnnanl (hat yw have gpod IWe a the mllatenl, free o1 all axunq inleruu axupl Inalgrven 10 Ne secs Ynlon and except for any tnunsl of a Boo-W make otenerof ffie collateral who has signed Na egnemenl In the Indfuled plan. s You wJl pay ail taxes, aeaeaamanls, end Gent ayinat or attarhed b Iha popery described snf lusher agroa to keep Ih4property in good condition, housdd ~n a audaDU ehag-r. You agree to axaatle trmenenpp eta emenk and:ewnry apnsmatt amendments st the endd unwn's riqueat end vvi11 eland th• propery against educe third parry chime 6. You will rstaintain Inaunnq fo cowl. ~ny,whicla or otDOr properly In wnicn m^ GeWI unbn na a seventy ntanal. 7 ra meunnu will W n a krm and m amount ulldactary to the Ueda union. You will cu~Wy the cntlil union with prnol of such meunnce unul all conic owed to cr-dd ~nidM1 end uourod by thb grape rtrNy m reooNd. If 7ou faJ fo nwnlRin aurh naunnce, uadit umm~ may hit is not requued lo, obleln Insunrtu of our own and add Iha boat or weh to the suns awed. This cost veil bee interest al lM COnlnd rate unUt paid Vou !urlner assign to the credal union the nphl to recelw the pnueds al anY inwnna on such property, and dlred airy insurer to pay those proceeds dressy to Getlil union, Yw eutMdiq yie ixeda union to sndone any theGpk or doll prowdad ea the propeds of such msvrona, end apply those procnda to IM sums cured b the crodil union Yw tunher aulhorge the vedil union to provide your Insurance Service Center vein the nanefary m(ermalion for ven6cation of adequate mwnga, You admmNadge thel'nwnnce or an exlencim Uterecf, placed W the cradil union is wnhoul be ne(rt la yw indivldueey hul is pnmerily forme pro(edion of Iha credg union. 6. 6hould Ne crodil union IeU at any rime That Ute aaarity presented has dlrrinbhed ~ wlue. or for t~n~r reason Seel met addrtionat awrh~ Is reputed, ou spree to,aas qn to credit un d wstNn ten (tc) days atewr W awns sewn~y the CrodU union feels Is rleussary to protect the credit unbn spaniel oosside loss. e. TM Crotld upon u hereby appointed as yWr Allome -In-Fad to pertorm en acre wnlcn the rndll unbn task an nauctary a pro~ect IM collateral and Ire severity bteml whkh the agrsemenl croalea g, It then is moro Ihen one bDflCWer, your Obil ^hona under Ihib BDffelMnt aro Joht antl eevenl, each being equally responsible to IuKiH Ne terms or this agreement. 10. Thif Security 9greemenl rot only Clods you, but your executors, sdrninistniurs, heirc, and seaigne. r,tOC 2/99 ComnctuN Pledge or shares: You pledge all goer shares and Mpodh In ih• credit union, Indudlnq torero atld8lons, as security for tMe ban. In cue you default, tM credit union may apply these shares and depoeitr to the payment of all soma tlw at the time o/ Wlaull. Indudlnq costs o} collaedon and meonab• snornay'e lac, that Ma credit union may Ineu4 up to 2D7G or tM unpaid principal and lnnrut. No Ilan or right to Impress a INn on shares and depoalis atrll apply to arty of your shares which may tx held In ^n "Individual R•Ikam•nt Account" or "Keogh Pqn.' Page 2 or 2 AFL THAT CLR1'AtN treat or p~reol ofi land situ~to ir7 East Penns~Qro T~owrtisi~ip, ~t~mberland Cr~ur~ty, ~er~nsyivan(~; rnara particularly saaund~d ~r-d described in ~ccordanca with ~ ~Urv~y Qi L7. P. R~tfensparger, r~gi~terac>E surre~rvr, ~Carnp Hili, Pennsylvania, d$teti t7~cernber t , 19g7, as follows, B~~lNNIN~ ~t a point an the Southerly iln~ of ~lenwaod Drive West) wntch paint is 154.66 feet in an $~~tQr-ly dlrectlor~ trrim the sauthe$~terly camar of ~rfard-Road (-West) and G(enuravd Driue (UV_Q,st}, and at tiiv(dinc~ Iine between f.ots frlos. 2~ and six, t3lcxck G, on the he'r~irtaftar mentioned Plan of LatS; lhenoe along $t~uthQrly !(n~ pf C.ylenwood Drive ~Vltest) in an arc having a radius of 17'5 feet i~ ~ nQrtfleasterty directl~n tQ the left 3~,5t3 feet tv a point at d(vitfirtg line between t.at Nos. ~ 1 end 2f X, Stock C, an $~id Flan; thane along said dividing line South thirty~sl~c dogrees fifty-one minutes East (S 36° 51' E) and thr~~gf~ the certtor of ~ partition well $rtd bsyond; 111.2 fiat to a paint at dividing line t~+atwean ~ot~ NQS. 3 end 21X. Block G, on ~ai~l Plan; thence alort~ said dividing lir'r~ South Sixty Qta degrees ~®ro minutes West (~ COQ UO° illt) 53.~~ feet to a point at dividing line [Said llrye-erroneously not irlc(uded in prior dead of record) betwdan Lets Nos. 21X ar:d 22, aIOCk G, afor~s~id; thence elon~ paid dividing line North M+onty- six degrees elevon minutes Ull~st ~N ~6° 11' W) iCt~,$1 ti'set to a point, th® pl~~e of gE~lNNING. $EiNQ Lot tvq. ~1X, Block ~ on flan Na, it?, Ridley Bark, which plan is r~co,d$d In tea Office of the ~ocorder of Doeds In end fflr C+~mberl~r~cl CQUnty, penr}sylv2t~ia in ~lar~ aook 18, P~g$ 47, HAVINCa thereon erected: a two-s3ory serrai-detached frame dwelling knawr~ end r~umbe-~d as 2pt3 Glenwood Drive, West, damp Hlil, Pennsylvania 17x11, BEING the same premises which Steven M. Yates and Yana S. Yates, husband and wife, by their deed dated Apri128, 2000 and recorded in Cumberland County on May 3, 2000 to Record Book 220, Page 480, granted and conveyed unto Eric R. Thornton and Mary E. Kanish-Thornton, husband and wife. Exhibit `B" ~r~el; C~1-l~-f ~c 3l8 ,~ Prepared By: Members 1st FCU 5000 Louise Drive 1 Mechanicsburg, PA 17055 ,~~~ ;V Return To: Members 1st FCU •-' Real Estate Department 5000 Louise Drive QQQCOK Mechanicsburg, PA 17055 (717)-795-6026 MORTGAGE Made 06/28/2010 Between Eric Thornton and Mary E Kanish-Thornton (hereinafter called "Mortgagor";~ And MEMBERS 1ST FEDERAL CREDIT UNION (hereinafter called "Mortgagee") Whereas, Mortgagor has executed and delivered to Mortgagee a certain Mortgage Note (hereinafter called the "Note") of even date herewith, payable to the order of Mortgagee in the principal sum of $ 29,500.00 ,lawful .money of the United States of America, and has provided therein for payment of any additional moneys loaned or advanced thereunder by Mortgagee, together with interest thereon at the rate provided in the Note, in the manner and at the times therein set forth, and containing certain other terms and conditions, all of which are specifically incorporated herein by reference; Now, Therefore, Mortgagor, in consideration of said debt or principal sum and as security for the payment of the same and interest as aforesaid, together with all other sums payable hereunder or under the terms of the Note, does grant and convey unto Mortgagee, All that certain property of the Mortgagor located in EAST PENNSBORO TOWNSHIP Cumberland County, Pennsylvania PLEASE SEE EXH161T "A" which currently has the address of_ 20B W GLENWOOD DRIVE _ __ [Streets CAMP HILL _, Pennsylvania [City] Acct No= ~ AppII) 4111710002 17011 [Zip Code] Page 1 of 4 Exhibit "C" Together with the buildings and improvements erected thereon, the appurtenances thereunto belonging and the reversions, remainders, rents, issues and profits thereof. To Have and To Hold the same unto Mortgagee, its successors and assigns, forever. Provided, However, That if Mortgagor shall pay to Mortgagee the aforesaid debt or principal sum, including additional loans or advances and all other sums payable by Mortgagor to Mortgagee hereunder and under the terms of the Note, together with interest thereon, and shall keep and perform each of the other covenants, conditions and agreements hereinafter set forth, then this Mortgage and the estate hereby granted and conveyed shall become void. This Mortgage is executed and delivered subject to the following covenants, conditions and agreements: (1} The Note secured herebyshal] evidence and this Mortgage shall cover and be security for any future loans or advances that may be made by Mortgagee to Mortgagor at any time or times hereafter and intended by Mortgagor and Mortgagee to be so evidenced and secured, and such loans and advances shall be added to the principal debt. (2) From time to time until said debt and interest are fully paid, Mortgagor shall: (a) pay and discharge, when and as the same shall become due and payable, all taxes, assessments, sewer and water rents, and all other charges and claims assessed or levied from time to time by any lawful authority upon any part of the mortgaged premises and which shall or might have priority in lien or payment to the debt secured hereby, (b} pay al] ground rents reserved from the mortgaged premises and pay and discharge all mechanics' liens which may be filed against said premises and which shall or might have priority in lien or payment to the debt secured hereby, (c) pay and discharge any documentary stamp or other tax, including interest and penalties thereon, if any, now or hereafter becoming payable on the Note evidencing the debt secured hereby, (d) provide, renew and keep alive by paying the necessary premiums and charges thereon such policies of hazard and liability insurance as Mortgagee may from time to time require upon the buildings and improvements now or hereafter erected upon the mortgaged premises, with loss payable clauses in favor of Mortgagor and Mortgagee as their respective interests may appear, and (e) promptly submit to Mortgagee evidence of the due and punctual payment of all the foregoing charges; provided, however, that Mortgagee may at its option require that Burns sufficient to discharge the foregoing charges be paid in installments to Mortgagee. (3) Mortgagor shall maintain all buildings and improvements subject to this Mortgage in good and substantial repair, as determined by Mortgagee. Mortgagee shall have the right to enter upon the mortgaged premises at any reasonable hour for the purpose of inspecting the order, condition and repair of the buildings and improvements erected thereon. Acct No - AppID 41 1 1 ~ 1 ~~~2 Fage 2 of 4 (4) In the event Mortgagor neglects or refuses to pay the charges mentioned at (2) above, or fails to maintain the buildings and improvements as aforesaid, Mortgagee may do so, add the cost thereof to the principal debt secured hereby, and collect the same as a part of said principal debt. (5) Mortgagor covenants and agrees not to create, nor permit to accrue, upon all or any part of the mortgaged premises, any debt, lien or charge which would be prior to, or on a parity with, the lien of this Mortgage. (6} In case default be made for the space of thirty (30) days in the payment of any installment of principal or interest pursuant to the terms of the Note, or in the performance by Mortgagor of any of the other obligations of the Note or this Mortgage, the entire unpaid balance of said principal sum, additional loans or advances and all other sums paid by Mortgagee pursuant to the terms of the Note or this Mortgage, together with unpaid interest thereon, shall at the option of Mortgagee and without notice become immediately due and payable, and foreclosure proceedings may be brought forthwith on this Mortgage and prosecuted to judgrhent, execution and sale for the collection of the same, together with costs of suit and an attorney's commission for collection of five percent (5%) of the total indebtedness or $Z00, whichever is the larger amount. Mortgagor hereby forever waives and releases all errors in said proceedings, waives stay of execution, the right of inquisition and extension of time of payment, agrees to condemnation of any party levied upon by virtue of any such execution, and waives all exemptions from levy and sale of any property that: now is or hereafter may be exempted by law. ('~) Upon payment of all sums secured by this Mortgage, this Mortgage and the estate conveyed shall terminate and become void. After such occurrence, Mortgagee shall discharge and satisfy this Mortgage. Mortgagor shall pay any recordation costs. Mortgagee inay charge Mortgagor a fee for releasing this Mortgage, but only if the fee is paid to a third party for services rendered and the charging of the fee is permitted under Applicable Law. The covenants, conditions and agreements contained in this Mortgage shall bind, and the beneftts shall inure to, the respective parties hereto and their respective heirs, executors, administrators, successors and assigns, and if this Mortgage is executed by more than one party, the undertakings and liability of each shall be joint and several. 4111710002 Acct No _ AppIl~ Page 3 of 4 Witness the due execution hereof the day and year above /written. C~ __ Eric Thomton Mary E Ka ' -Thomton Commonwealth f Pennsylvania ) ss: County of ) this, the ~ ~ day of _ , 2010 ,before me, I ,the ndersigned officer, personally appeared satisfactorily proven to me to be the person(s) whose name(s) is/are subscribed to the within Mortgage, and acknowledged that he/she executed. the same for the purposes therein contained. In Witness Whereof, I hereunto set my hand and offici My commission expires: COMMONWEALTH OF PENNSYLVANIA Notarial Seal Jody L. Travis, Notaty Publlc Lower Allen Twp., Cumberland County My Commission Ex ices Sspt. 29, 2012 Member, Pennsylvali ~ A9~1'i~lation of Notaries Certificate of Residence of Mortgagee Members IST Federal Credit Union, Mortgagee within named, hereby certifies that its residence is 5000 Louise Drive, Mechanicsburg, PA 17055. By ~~lo~ Acct too __ AppID 41 I 1710002 Sege a of 4 Omer ~~~~:,,: Legal Description 09-16-1050-318 ALL THAT CERTAIN tractor parcel of land situate in East Pennsboro Township, Cumberiar,d County, Pennsylvania, more particularly bounded and described in accordance with .a survey of D. P. Raffensperger, registered surveyor, Camp Hill, Pennsylvania, dated December 'I 1967, as follows: BEGINNING at a point on the southerly line of Glenwood Drive (West) which point is 1L>4.66 feet in an easterly direction from the southeasterly corner of Erford Road (West) and Glenwood Drive (West), and at dividing line between Lots No. 22 and 21X, Block G, on 1:he hereinafter mentioned Plan of Lots; thence along southerly line of Glenwood Drive (Westj in an arc having a radius of 175 feet in a northeasterly direction to the left 32.58 feet to a pr_ai nt at dividing line between Lot Nos. 21 and 21X, Block G, on said Plan; thence along said dividing line South thirty-six degrees fifty-one minutes East (S 36 degrees 51' E) and through the center of a partition wall and beyond, 111.22 feet to a point at dividing fine between Lots No. 3 and 21X, Block G, on said Plan; thence along said dividing line South Sixty 60 degrees Zero minutes West (S 60 degrees 00' W) 53.00 feet to a point at dividing line [said line erroneously not included in prior deed of record] between Lots Nos. 21X and 22, Block G, aforesaid; thence along said dividing fine North twenty-six degrees eleven minutes West (N 26 degrees 11' W) 109.81 feet to a point, the place of BEGINNING. Subject to any restrictions, easements and/or adverses that pertain to this property. ROBERT P. ZIEGI.ER RECORDER OF DEEDS CUMBERLAND COiJNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-2,~0-6370 Instrument Number - 201020510 Recorded On 7/29/2010 At 8:06:28 AM; * Instrument Type -MORTGAGE Invoice Number - 69909 User ID - AF * Mortgagor - TIIORNTON, ERIC R * Mortgagee -MEMBERS 1ST FEDERAL CR UN * Customer -MEMBERS * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $23.50 JUSTICE RECORDING FEES - $13,50 RECORDER OF DEEDS PARCEL CERTIFICATION $10..00 FEES ~ AFFORDABLE HOUSING $11..50 COUNTY ARCHIVES FEE $2.,00 ROD ARCHIVES FEE $3..00 TOTAL PAID $64,.00 * Total Pages - 6 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA ~y op cuM~~ v2 ~~o RECORDER O D EDS t~so * -Information denoted by an asterisk may change during the verification process and may not be reflected nn this page. IIIIIIIIII@I[Illtllll (Rev. 9/2008) Date: August 29, 2012 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mor~ga~e on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached napes. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions. o~ u may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (7171 780-18691. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARR UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Exhibit "D" HOMEOWNER'S NAME(S): ERIC THORNTON MARY E KANISH-THORNTON PROPERTY ADDRESS: 20B W GLENWOOD DRIVE CAMP HILL, PA 17011 LOAN ACCT. NO.: ORIGINAL LENDER: Members 1" Federal Credit Union CURRENT LENDER/SERVICER: Members le` Federal Credit Union HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • IF YOU HAVE .A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORF.Ci,OSTTRE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting; with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST O .` R WITHTN THIRTY-THRRF, «3) DAYS OF TH DAT OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE_YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSTTMER CREDIT CO TN4 ,IN AG ,N .I ,S -- If you meet with one of the consumer credit counseling agency listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at 'the end of this Notice. 1t is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORT AG , AS4IS AN -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE ,A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF "1~HE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED-FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION V1~ILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT' ANY TIME BEFORE A SHERIFF'S SALE, THE; FORECLOSURE WILL BE STOPPED. Page 2 of 5 AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.] HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to datel. NATLIRF, OF THE DEFAULT --The MORTGAGE debt held by the above lender on your property located at: ZOB W GLENWOOD DRIVE CAMP HILL, PA 17011 -_ IS SERIOUSLY IN DEFAULT because: A. YOU HAVF, NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: for June 24 2012 in the amount of 360.88, for July 24 2012 in the amount of 361.14 and Airgllet ?4 2f11 in he amo mt of 361.14 __-_______ Other charges (explain itemize) TOTAL AMOUNT PAST DUE: $1,083.16 __~~ B. YOU HAVE FAILED TO "CAKE THE FOLLOWING ACTION (Do not use if not applicable):. HOW TO CURE THE DF.FAUL.T --You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 1,083.16 , PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE IaURING THE THIRTY (30) DAY PERIOD. Payments must be made either b~ cash, cashier's check, certified check or monkorder made payable and sent to: Members I~` Federal Credit Union, ATTN: Tracey 5000 Louise Drive Mechanicsbure, PA 17055 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) Page 3 of 5 IF YO 1 DO NO JR , TH . D .FA .T--II' you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate__the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. if full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose u~2n your mortgaged property. IF THE MORTGA TE IS FORF, ,OS .D JPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. I~you cure the default within the THIRTY (301 DAY .ern iod• you wilt not he re~iired to ~y attorney c fees. OTH .R ..ND ,R REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR 'TO SHERIFF'S SALE -- 1f you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by pavin¢ the total amount then past due plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately Three (3) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. Name of Lender: Members 1`~ Federal Credit Union Address: 5000 Louise Drive Mechanicshurg, PA 1?055 Phone Number: 717-506-5438 or j80~] 283-2328 F.xt. 5438 Fax Number: (7171 795-5207 Contact Person: Tracey E-Mail Address: MackgyTanmemberslst.org F,FFECT OF SHERIFF'S SAi,F -- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the. Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORT rAG , -- You _may or XX may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. Page 4 of 5 • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF'. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEV:ER, YOU DO NOT HAVE THIS RIGHT TO Ct iRE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAV~JSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, • TO ASSERT ANY OTHF,R DEFENSE ~'OU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION tTNDER THE FEDERAL BANKRUPTCY LAW. jFill in a list o~'all Counseling Agencies listed in Annend~Y C. FOR THE COUNTY in which the nroverty is located. i!sir~g additional ~gg~if necessarvl. Certified Mail # 91 7199 9991 7031 7829 3228 Page 5 of 5 • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT' OR TO BORROW MONEY FROM .ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY A.NY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO Ct;RE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER. THE MORTGAGE DOCUMENTS, • TO ASSER"t ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE T'O SUCII .ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE F1=,DERAL BANKRUPTCY LAW. Certified Mail # 91 7199 9991 7031 7829 3235 Page 5 of 5 Comprehensive Housing Counseling Agencies Pfi N iYw M ICMCB J-'4~FC Agencias de Consejo al Cliente para Vivienda Cumberland County ~ *CCCS of Western PA -York 55 Clover Hill Road Dallastown PA 17313 888.511.2227 ! 888.511.2227 v~nvw cccspa.ora Community Artion Commission -Capital Region 1514 Derry St Harrisburg PA 17104 717.232.9757 www. cactricounty. ora Harrisburg Fair Housing Council 2100 N 6th 5t Harrisburg PA 171 ? 0 717.238.9540 Housing 8 Redevelopment Authority -Cumberland Cnty I14 N Hanover St; STE 104 Carlisle PA 17013 866.683.5907 / 717.249.0789 www.cchra.com Pathstone Corporation Pennsylvania 1625 North Second St Harrisburg PA 17102 717.234.6616 www.ruralisc.orq(pathston~pa htm Pennsylvania Interfaith Community Programs, Inc. 40 E High St Gettysburg PA 17325 717.334.1518 www adamscha oro NOTE: Many of the agencies offer workshops at various location sites; call to find a location near you. _~ Report last updated: 4/30/2012 9:03:04 AM Page 1 of 1 Servicemembers Civil U.S. Department of Housing MB Approval No. 2502-0565 Relief Act and Urban Development I'exp d/30/2007) Notice Disclosure Office of Housing Servicemembers on "active duty" or "active service," or a dependent of such a servicemember may be entitled to certain legal protections and debt relief pursuant to the Servicemembers Civil Relief Act (SG USC App. §§ 501-596) (SCRA). Who Mav Be Entitled to L.e~al Protections Linder the SCRA? .A.ctive duty members of the Army, Navy, Air Force, Marine Corps, Coast Guard, and active service National Guard; • Active service members of the commissioned corps of the National Oceanic and Atmospheric Administration; Active service members of the commissioned corps of the Public Health Service; United States citizens serving with the armed forces of a nation with which the United States is allied in the prosecution of a war or military action; and • Their spouses. What .gal Protections Are Servicemembers Entitled To LTnder the SCRA? The SCRA states that a debt incurred by a servicemember, or servicemember and spouse jointly, prior to entering military service shall not bear interest at a rate above 6 percent during the period of military service. The SCRA states that ir; a legal action to enforce a debt against real estate that is filed during, or within 90 days after the servicemember's military service, a court may stop the proceedings for a period of time, or adjust the debt. In addition, the sale, foreclosure, or seizure of real estate shall not be valid if it occurs during, or within 90 days after the servicemember's military service unless the creditor has obtained a court order approving the sale, foreclosure, or seizure of the real estate. The SCRA contains many other protections besides those applicable to home loans. How Does A servicemember or Denendent Request Relief Under the SCRA? • In order to request relief under the SCRA, a servicemember or spouse, or both, must. provide a written request to the lender, together with a copy of servicemember's military orders. The Lender providing this Notice is Members 15` Federal Credit Union, ATTN: Arlanda Dintaman, 5000 Louise Drive, Mechanicsburg, Pennsylvania, 17055. The phone number is toll free (800) 283-2328. How Does a servicemember or Dement Obtain Information About the 4 .RA? The U. S. Department of Defense's information resource is "Military OneSource" W'ebsite: htt~://www.militarvonesource.com The toll free telephone number for Military OneSource are: o From the United States: 1-800-342-9647 o From outside the United States (with applicable access code): 800-3429-6477 o international Collect (through long distance operator): 1-484-530-590$ Servicemembers and dependents with questions about the SCRA should contact. their unit's Judge Advocate, or their installation's Legal Assistance Officer. A military legal assistance office locator for all branches of the Armed Forces is available at http://le~alassistance.law.a£mil/content/locator.php form HUD-92070 (2/2007) j-c~pc ~ ~ , ~ ~c.,, {~; ~'vnfirm ,1 Sps ~,~I>,~e Us~s.f~. ~,~/~' Track & C,onfirrn r~~~~ l ~..,~r~ ~~11R . ~:~FE~ NUMB:... vi- yS17-~J IS:i Z.A Check on Another Item Whafs yow~ labe~ ;or receipt) number? z;h'q: ~ F'ackagr _ . ~..~ iv ~ ~, ~ r;. ;n _1~u1: 1~~~~ ~ at i ~. SERVICE STATUS OF YOUN ITEM DATE 8 TIME _OC ATION ' Fl~.'t Ii c.S First-Class Mall Delivered September Cd, 201L, 5 V pm CAMP HILL PA 1'C 1 expected Delivery By: ~.~q~. st 30, 2012 Hotvn Receipt F.lem ronlc Notice Left August 31 2012, 12.35 pm CAMP HILL.. PA ~ i^~ Depart USPS Sort August 30. 2012 HARRISBURG. P,A 1?'f 0 Facility Processed at USPS August 30, 2012, 12.38 am HARRISBURG, PA 1 ~ t0-' Ongin Sort Facility Electronic Shipping Info August 29, 2012 Receivea Dispatched to Sort August 29, 2012, 7 13 pm MECHANICSBUR3. PA '.T„~o Facil Ity Acceptance August 29. 2012, 414 pm MECHANICSBUG:S, PA'? Cd5 Find LEGAL ON USPS.COM pig..; ~~y ~'to ~, vovernment Services T , irs v .. Buy Stamps 8 Shop Fn,~, ~nnt a Label wito Postage FE41 Ft :i Dza Customer Service I Ste Index ON ABOUT.USPS.COM vbout USPS Hcme ~dewsroom Mal SeNlce Up7a;es Fo'm; 8 P tli ahoes C~~reP~i Exhibit "E" OTHER USPS SITES Bu~me~ _.i_~i~ertialeway, r -ctt ~'S Po i~ v c~rr https:/!Cools.usps.com/go/TrackConfir~iAction_input?origTrackNum=9171999991703 l 78... 10/5/2012 USYS.co~l.~~ - ~hrack & Confirm /~ English Customer Service USPS Mobile 6~ Vas/ ~.\rWi Search IiSPS; :..:u. ., ,, ick Packages (`kick -o, Shp a Package Send Mail Manage Your Mail Shop .,~Iness Solctions YOUR _ARE'_NUMBEF; SERVICE STATUS OF YOUR ITEM DATER TIME LOCATION fEAT~.~RES flt'1 w49991703~~e293235 First-Class Maih° Delivered September 04, 20'12, 517 pm CAMP HILL. PA 170'1'• Expected Delivery By: August 30, 20"12 Rehm Receipt F15C-onic Page 1 of 1 Registerl Sign In Track & Confirm .. ., .. _i _.... PRIVi DETAILS Notice Left August 3r. 2012, 12:35 pm CAMP HILL, PA 1 i0~' Depart USPS Sort August 3U, 2012 HARRISBURG, PA 1710" Facility Processetl at USPS August 20. 2J~2, 1238 am HARRISBURG, f~A 1" ~0- Origin Sort Facility Electronic Shipping Info August 29, 2012 Receives Dispatched to Sort August 29. 2012. 7 13 pm MECHANICSBURG. PA ' 7055 Facility Acceptacce August 29. 2012, 4' 14 pm MECHANICSBURG, PA' T)55 Check on Another Item WnaCs dour label ;or receipt) number? LEGAL ON USPS.COM i. acy Po : . Governmert Sanices Terms of ~ -a ~ Buy Stamps & Shop ~ ~=C'~ Pint a Label with Postapa ti r =E?.f ~r0 Dal3 Customer Servlca S[e Inde., find ON ABOUT.USPS.COM About JSPS Home News~oom , Mac Service Lpaes Forns & P u~l ~a.io~15 , ~arec s OTHER USPS S.TES Bus ~. ~. ateway POS:di Ir~al inspe<. Pos c J~iur ~_. f ;nis Fese~. e~ httns://tools.usps.com/~o/TrackConfirmAction input?origT'rackNum=917199999170317K... 10/5/2012 10/10/2012 21:47 7179320317 KARLLEDESOHM PAGE 07107 MEYIBERS 1ST FEI7I/RAL CREDIT UNION PLATN'TII~ I' •Vs. Ml1RY' ?., KANISH-THORNTON ERTC R. THORNTON allc/a ERIC TI-IORNTON DEFENDANT(S) : IN TIDE COURT OF COMMON PLEAS CCIMBBRLAND COUN~'Y, PENNSYLVANIA NO.: CIVIL ACTION-I.,AW~MORTGAG)/ >~'ORECLOSURE VER)<F)<CA')ciQN I, Dan Summers, Collectionns Manager for Meznbexs 1 ~` Fedexal Credit Union, being authorized to do so on bEhalf of Members 1~` rederal Credit Union, hereby verify that the statements made in the fore~aing pleading axe true axtd correct to the best of my information knowledge az~d belief. I understand that false statements axe made subject to the penalties o:f 18 Pa. C.S.A. Section. 4904, z•elating to unsworn falsification to authorities. Members 1. S` Fedexal Credit Union Dail Summers, Collections Manager Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0]73 (717)938-6929 MEMBERS 1 `" FEDERAL CREDIT UNION PLAINTIFF V s. MARY E. KANISH-THORNTON F,RIC R. THORNTON a/k/a ERIC THORNTON DEFENDANTS ' ,<~~~ IN THE COURT OF COMMON PLF,AS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW MORTGAGE FORECI OSURE NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you. to lose your home. Il'you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in acourt-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and i:ile a Request for Conciliation Conference with the Court, which must be filed with the Court. within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet: with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. R~ec s~ ~~ `~ 1~/ " ;~ ; r Date: October 15, 2012 ..-= ',r ~~-~' ~~` .-~~ ~~ ~, arl M. Ledebohm, Esy. Supreme Court ID #59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717) 938-6929 Attorney for Plaintiff FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for Hardship assistance, your lender must consider your circumstances to determine possible options while working with your ____ Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: Is the property for sale? Realtor Name: Borrower Occupied? Mailing Address (if different) City: Phone Numbers: Email: # of people in household: Mailing Address: City: Phone Numbers: Email: # of people in household: First Mortgage Lender: _ Type of Loan: Loan Number: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Date of Last Payment: Yrimar~~ Reason for Default: _ State: Zip: Yes ^ No ^ Listing date: Price: $___ _ _ ___ Realtor Phone: _ _ Yes ^ No ^ :Home: Celi: State:__Zip: Office: Other: How long? State:__ ___Zip: :Home: CeII: Office: Other: How long? Date You Closed Your Loan: Included Taxes & Insurance: is the loan in Bankruptcy? Yes ^ No ^ ~. 1 If yes, provide names, location of court, case number & attorney: Assets Amount Owed: Value: _ Home: $ ____ $ - Other Real Estates $ $-- -- Retirernent Funds: $ $ Investments: $_- .___ $ - -_--- - ~ Checking: $ $ - Savings: $ $ - Other: $ $ Automobile #1: Model Amount owed: _ Value: Automobile #2: Model: Amount owed: _ Value: Other transportation (automobiles, boats motorcycles): Model: year: Amount owed: Value_ Monthly Income Name •of Employers: 2 . -- ---- _-_ - -------- 3 . ---- - ---- ------- Additional Income Description fnot wages): 1,__ monthly amount: 2, monthly amount: _ Borrower Pay Days: - Co-Borrower Pay Days: ______ Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT__ __ M_~°rt~PL_ ~- 2° 1vi01"tgage Food Ut1I1t1eS --------~ _`.-- Car Payment s - Auto Insurance Condo/Nei h. Fees Med. not covered _ __________ -___^ Auto fuel/re airs Other ro a ment _________ Install. Loan Pa ment Cable TV __,__-. Child Support/Alim. Dav/Child Care/Tuit. S endin Mone Other Ex enses _____ ___________ Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ^ No ^ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): _~_ _- Fax:__ Year: Year: ,, Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HFMAP) assistance? 'y'es ~~ ?~10 if yes, please indicate the status of the application:_ ____ ______,_ 1-Iave you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ^ No ^ If yes, please indicate the status of those negotiations: ______,~ Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Servicing Company (Name): Contact; Phone: Phone: I/wee ___ _ ,authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. UWe understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Date Co,Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: V Proof of income Past 2 bank statements IIYll Proof of any expected income for the last 45 days _V( Copy of a current utility bill V Letter explaining re~ison for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson - ,.- ,_ ~... Sheriff ~ • - ,t i ` Jody S Smith u ~ ,,~ Chief Deputy ~~?!~ ~~t,; _~ ~~ ~~: ~ ~ Richard W Stewart Solicitor ~Ej~9~~t~.rk ;u E,~,I.~~,•?',` ~~~N ~`!~ `'l~',id~i~ Members 1st FCU vs. Case Number Mary E. Kanish-Thornton (et al.) 2012-6479 SHERIFF'S RETURN OF SERVICE 10/25/2012 05:51 PM -Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on October ?_5, 2012 at 1751 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: Eric R. Thornton, by making known unto himself personally, at 206 W. Glenwood Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to h!m personally the said true and correct copy of the sarrre. UTSHALL, D 10!25/2012 05:51 PM -Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on October 25, 2012 at 1751 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: Mary E. Kanish-Thornton, by making known unto herself personally, at 206 W. Glenwood Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. r GUTSHAL ,~~6EPUTY SHERIFF COST $59.00 November 02 2012 SO ANSWERS, I, ~~-' RONNY R ANDERSON, SHERIFF Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1' ` FEDERAL CREDIT UNION PLAINTIFF Vs. MARY E. KANISH-THORNTON ERIC R. THORNTON a/k/a ERIC THORNTON DEFENDANTS i~~t~. _ r lr. L ~. ... ~ v, j I iy~..,,~ ! ,l i~7 ~ C.` ~.J it +'' ~ t +~~4 I'a IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 12-6479 Civil CIVIL ACTION -LAW MORTGAGE FORECLOSURE PRAECIPE TO SETTLE. DISCONTINUE AND. END To the Prothonotary: Please mark the docket in the above captioned case settled, discontinued and ended without ureiudice. Ke~~IY ~~n~, ~..- /, f---!f ~i Date: November 13, 2012 G 1 IvI. Ledebohm, Esquire Supreme Court ID #59012 ~' P.O. Box 173 ~ New Cumberland, PA 17070-0173 (717)938-6929 Attorney for Plaintiff ~ • Karl M. Ledebohm, Esquire P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929 MEMBERS 1sT FEDERAL CREDIT UNION PLAINTIFF Vs. MARY E. KANISH-THORNTON ERIC R. THORNTON a/k/a ERIC THORNTON DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: 12-6479 Civil CIVIL ACTION -LAW MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, Karl M. Ledebohm, Esquire, hereby certify that on the 14~' day of November, 2012, I served a true and correct copy of the Praecipe to Settle, Discontinue and End in the above captioned matter upon the following by first class mail, postage prepaid, addressed as follows: Mary E. Kanish-Thornton Eric R. Thornton 20-B West Glenwood Drive 20-B West Glenwood Drive Camp Hill, PA 17011 Camp Hill, PA 17011 R ctfuJl~~i 'tted~ Date: November 14, 2012 G'~-~ f~ ~ ~;-'~'J Karl M. Ledebohm, Esq. Attorney for Plaintiff Supreme Court ID #: 59012 P.O. Box 173 New Cumberland, PA 17070-0173 (717)938-6929